GST adjudication cannot add interest or penalty beyond the show cause notice; enlarged demands were quashed and remitted.

An adjudication order under GST cannot confirm interest or penalty on grounds not specified in the show cause notice, because section 75(7) confines the decision to matters put to the noticee. Where the notice proposed only tax liability and the final order added interest and penalty, the enlargement of demand was contrary to the statutory mandate and arbitrary. The adjudication order and consequential attachment were quashed, and the matter was remitted to the authority for fresh adjudication.

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Issues: Whether the adjudication order could sustain the levy of interest and penalty when the show cause notice did not propose such levy, and whether the consequential demand and attachment orders were liable to be quashed.

Analysis: Section 75(7) of the Central Goods and Services Tax Act, 2017 prohibits confirmation of demand on grounds not specified in the notice and restricts the adjudication order to the matters put to the noticee. The show cause notice in the present matter proposed only tax liability for the relevant financial year and did not indicate any proposal for interest or penalty, yet the final order imposed both. Such enlargement of the demand beyond the notice was found to be contrary to the statutory mandate and arbitrary.

Conclusion: The adjudication order imposing interest and penalty without prior proposal in the show cause notice was unsustainable and was quashed, along with the consequential attachment order, with the matter remitted to the adjudicating authority for fresh decision.

Final Conclusion: The petition succeeded, and the impugned orders were set aside with a direction for fresh adjudication.

Ratio Decidendi: An adjudication order under the GST law cannot confirm tax, interest, or penalty on grounds not specified in the show cause notice.

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